HARBOR FLORIDA BANCSHARES, INC. AND HARBOR
                FEDERAL SAVINGS BANK CODE OF ETHICS FOR FINANCIAL
                                 PROFESSIONALS


This Code of Ethics for Financial Professionals applies to the Chief Executive
Officer and senior financial officers (Chief Financial Officer and Controller).
Harbor Florida Bancshares, Inc. and Harbor Federal expects all of its employees
to act in accordance with the highest standards of personal and professional
integrity in all aspects of their activities, to comply with all applicable
laws, rules and regulations, to deter wrongdoing and abide by the Code of Ethics
and other policies and procedures adopted by Harbor Florida Bancshares, Inc. and
Harbor Federal that govern the conduct of its employees. This Code of Ethics is
intended to supplement the Harbor Federal Code of Ethics.

You agree to:

(a) Engage in and promote honest and ethical conduct, including the ethical
handling of actual or apparent conflicts of interest between personal and
professional relationships;

(b) Avoid conflicts of interest and to disclose to the Director of Human
Resources any material transaction or relationship that reasonably could be
expected to give rise to such a conflict;

(c) Take all reasonable measures to protect the confidentiality of non-public
information about Harbor Federal or its subsidiaries and their customers
obtained or created in connection with your activities and to prevent the
unauthorized disclosure of such information unless required by applicable law or
regulation or legal or regulatory process;

(d) Produce full, fair, accurate, timely, and understandable disclosure in
reports and documents that Harbor Florida Bancshares, Inc. or its subsidiaries
files with, or submits to, the Securities and Exchange Commission and other
regulators and in other public communications made by Harbor Florida Bancshares,
Inc. or its subsidiaries;

(e) Comply with applicable governmental laws, rules and regulations, as well as
the rules and regulations of self-regulatory organizations of which Harbor
Florida Bancshares, Inc. or its subsidiaries is a member; and

(f) Promptly report any possible violation of this Code of Ethics to the
Director of Human Resources or any of the parties listed in the Harbor Federal
Code of Ethics.


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Harbor Florida Bancshares, Inc. and Harbor Federal Savings Bank Code of Ethics
for Financial Professionals.
Page 2 of 2

You are prohibited from directly or indirectly taking any action to fraudulently
influence, coerce, manipulate or mislead Harbor Florida Bancshares, Inc. or its
subsidiaries' independent public auditors for the purpose of rendering the
financial statements of Harbor Florida Bancshares, Inc. or its subsidiaries.

You understand that you will be held accountable for your adherence to this Code
of Ethics. Your failure to observe the terms of this Code of Ethics may result
in disciplinary action, up to and including termination of employment.
Violations of this Code of Ethics may also constitute violations of law and may
result in civil and criminal penalties for you, your supervisors and/or Harbor
Florida Bancshares, Inc.

If you have any questions regarding the best course of action in a particular
situation, you should promptly contact the Director of Human Resources or any of
the parties listed in the Harbor Federal Code of Ethics. You may choose to
remain anonymous in reporting any possible violation of this Code of Ethics.

Your Personal Commitment to the Harbor Florida Bancshares, Inc.  Code of Ethics
for Financial Professionals

I acknowledge that I have received and read the Harbor Florida Bancshares, Inc.
Code of Ethics for Financial Professionals and understand my obligations as an
employee to comply with the Code of Ethics.

I understand that my agreement to comply with the Code of Ethics does not
constitute a contract of employment.

Please sign here: ______________________________ Date: _______________

Please print your name: _____________________________


This signed and completed form must be returned to the Director of Human
Resources.